This is in response to your letter dated October 4, 1995, requesting an interpretation of the
Occupational Safety and Health Administration (OSHA) standards addressing ladders used to
support a hoisting wheel. Your letter references the use of a Ladder Master Hoisting Wheel,
and the need to adhere to the regulations for ladder use while involved in lifting materials
with this device.

Ladders are required to be secured to prevent accidental displacement when employees are using
them on unstable, slippery or non level surfaces. However, when using a ladder to lift
materials with a hoisting wheel, employees would not be using the ladder for climbing and
therefore would not be subjected to ladder use requirements.

When involved in this lifting activity, the ladder would not be considered a hoist for the
purposes of OSHA's hoisting regulations and would therefore not be subject to the provisions
of Subpart N-Cranes, Derricks, Hoists, Elevators, and Conveyors. However, those employees
exposed to fall hazards during lifting activities must comply with the applicable fall
protection requirements in accordance with 29 CFR 1926.500-503, (e.g. safety monitor for low
sloped roofs).

We agree, if used properly and within manufacturer's guidelines, this ladder hoisting wheel
could reduce or eliminate injuries from lifting heavy loads while climbing ladders.

Thank you for your interest in job site safety and health issues and if we can be of any further
assistance, please write to:

A product called the Ladder Master Hoisting Wheel has been sold into the construction trades for
decades. It is placed on the inside rungs (toward the building) for hoisting light loads to the
roof edge.

The worker on the roof grasps the handle end and pushes the ladder outward to his arms length
(the handle is 24" long). The worker on the ground, standing outside of the rungs so he is not
under the load, pulls the load up using a 3/4" manila rope.

Ladder mounted hoisting wheels are manufactured for both round rung and flee rung ladders.
Warning labels indicate that they are not to be used for loads exceeding the rating of the
ladder

Here is our problem:

A roofer in the Carolinas phoned today to say that he was confused. He acknowledges that he must
tie-off his ladder when his workers use it to more from one level to another. When he then
wants to use his ladder as a hoist, using the ladder mounted hoisting wheel, he cannot comply
with this provision since he could not raise the load.

When he installs the hoisting device on the ladder, it is no longer a ladder, it is now a hoist.
At this point. his hoist should be subject to safety provisions other than the ladder tie-off
rule.

Perhaps at this point, he would be subject to 29 CFR 1926.501(b)(3) under the duty to have fall
protection in a hoist area.

The use of these wheels is widespread. As the manufacturer, we would like lo issue proper
information and if needed create new safety labels for these products. The use of ladder mounted
hoisting wheels saves many a worker from back injury, while allowing them to focus on the job of
climbing a ladder, not carrying a load up or down the ladder.

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